Issue:
We very much welcome the progress made by considering curtain walls as windows. However, the technical screening criteria for the energy efficiency of transparent building components remain incorrectly defined, as neither climate differentiation nor solar energy gains are considered. The energy efficiency of transparent building components requires an energy balance assessment that accounts for both heat transfer and solar gains related to the respective climatic conditions.
The current pan-European maximum U-value of 1.2 W/(m²·K) for windows and transparent curtain walls addresses only thermal insulation and does not allow for geographical and climatic differences to be factored in to optimize resource and energy use. It rather promotes highly insulated and material-intensive windows and curtain walling everywhere in the EU without securing environmental payback.
For the full EuroWindoor feedback to the Public Consultation see the following link:
EuroWindoor feedback on revised Criteria for Windows and Curtain Walling in the EU Taxonomy Climate Delegated Act Mitigation, amendment to Section 3.5